Finding 544785 (2024-005)

Significant Deficiency Repeat Finding
Requirement
N
Questioned Costs
-
Year
2024
Accepted
2025-03-31
Audit: 351264
Organization: Chestnut Hill College (PA)

AI Summary

  • Core Issue: The College has not created a required written information security program, putting students' personal information at risk.
  • Impacted Requirements: This finding violates the Gramm-Leach-Bliley Act, which mandates that institutions protect sensitive data and explain their information-sharing practices.
  • Recommended Follow-Up: The College must develop and implement a comprehensive information security program, including specific policies on IT security, incident response, and risk management.

Finding Text

2024-005: Gramm-Leach-Bliley Act Federal Agency: U.S. Department of Education Federal Program Name: Federal Supplemental Educational Opportunity Grants; Federal Pell Grant Program; Federal Direct Student Loans; Teacher Education Assistance for College and Higher Education Grants Assistance Listing Number: 84.007, 84.063, 84.268, 84.379 Federal Award Identification Number and Year: P007A243557, P063P242088, P063Q232088, P268K252088 - 2024; P379T232088 - 2023 Award Period: July 01, 2023 - June 30, 2024 Type of Finding: • Significant Deficiency in Internal Control over Compliance • Other Matters Criteria or specific requirement: The Gramm-Leach-Bliley Act (Public Law 106-102) requires institutions to explain their information-sharing practices to their customers and to safeguard sensitive data. (16 CFR 314) The Federal Trade Commission considers Title IV-eligible institutions that participate in Title IV Educational Assistance Programs as “financial institutions” and subject to the Gramm-Leach-Bliley Act (16 CFR 313.3(k)(2)(vi)). Condition: Under an institution’s Program Participation Agreement with the U.S. Department of Education and the Gramm-Leach-Bliley Act, schools must protect student financial aid information, with particular attention to information provided to institutions by the Department or otherwise obtained in support of the administration of the federal student financial aid programs. Questioned costs: None Context: During our audit procedures, it was noted that the College had not developed and implemented an approved written information security program. Cause: The College did not develop and implement a written information security program as required by the Gramm-Leach-Bliley Act. Effect: The students’ personal information could be vulnerable. Repeat Finding: Yes, 2023-008. Recommendation: The College should develop and implement an approved written information security program and verify there is a risk management section that describes how the College is identifying, assessing and communicating risks. In addition, there should be a description on the evaluation of safeguard sufficiency in mitigating risks. The information security program should also include the following: • IT Security Policy • Acceptable Use Policy • Incident Response Policy • Data Classification Policies • Vendor Management Policy • Patch Management Policy • Data Disposal Policy • Risk Assessment Policy • Logical Access and User Access Review Policies • Evidence of Review by CIO/CISO and responsibility of program Views of responsible officials: There is no disagreement with the audit finding.

Categories

Student Financial Aid Matching / Level of Effort / Earmarking Subrecipient Monitoring Internal Control / Segregation of Duties Significant Deficiency

Other Findings in this Audit

  • 544776 2024-002
    Significant Deficiency Repeat
  • 544777 2024-003
    Significant Deficiency
  • 544778 2024-003
    Significant Deficiency
  • 544779 2024-003
    Significant Deficiency
  • 544780 2024-003
    Significant Deficiency
  • 544781 2024-004
    Significant Deficiency Repeat
  • 544782 2024-004
    Significant Deficiency Repeat
  • 544783 2024-005
    Significant Deficiency Repeat
  • 544784 2024-005
    Significant Deficiency Repeat
  • 544786 2024-005
    Significant Deficiency Repeat
  • 1121218 2024-002
    Significant Deficiency Repeat
  • 1121219 2024-003
    Significant Deficiency
  • 1121220 2024-003
    Significant Deficiency
  • 1121221 2024-003
    Significant Deficiency
  • 1121222 2024-003
    Significant Deficiency
  • 1121223 2024-004
    Significant Deficiency Repeat
  • 1121224 2024-004
    Significant Deficiency Repeat
  • 1121225 2024-005
    Significant Deficiency Repeat
  • 1121226 2024-005
    Significant Deficiency Repeat
  • 1121227 2024-005
    Significant Deficiency Repeat
  • 1121228 2024-005
    Significant Deficiency Repeat

Programs in Audit

ALN Program Name Expenditures
84.268 Federal Direct Student Loans $13.42M
84.063 Federal Pell Grant Program $2.80M
93.575 Child Care and Development Block Grant $376,644
84.031 Higher Education Institutional Aid $325,450
84.033 Federal Work-Study Program $142,920
84.038 Federal Perkins Loan Program_federal Capital Contributions $135,628
84.007 Federal Supplemental Educational Opportunity Grants $118,905
84.379 Teacher Education Assistance for College and Higher Education Grants (teach Grants) $3,772